Jr. v. People

Summary

Francisco Grumo, Jr., a truck driver, was convicted of reckless imprudence resulting in homicide after allowing Edric Dela Umbria to hitchhike on the unsafe back portion of his tractor head. On November 6, 2013, while driving along Marcos Road in Manila, Grumo permitted Edric to board the rear of his truck despite knowing this violated company policy and traffic regulations. Edric slipped and fell, was run over, and died from traumatic injuries. The Supreme Court affirmed Grumo's conviction, finding he acted with inexcusable lack of precaution and conscious indifference to consequences. The Court modified the penalty to an indeterminate sentence of 1 year 8 months to 3 years 6 months 21 days, and increased monetary awards to PHP150,000 total (civil indemnity, moral damages, and temperate damages). The case establishes that violating traffic regulations creates a presumption of negligence under Article 2185 of the Civil Code, and demonstrates criminal liability for reckless imprudence when safety violations directly cause death.